Southend Central Area Action Plan (SCAAP) - Revised Proposed Submission 2016

Object

Representation ID: 2842

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? Yes

Sound? No

Paragraph 128 refers to the "low rate of car ownership in Southend Central Area" and that this provides opportunities for other measures to facilitate the use of sustainable transport modes, such as cycle lanes and bus priority measures, together with inked improvements to the public realm.
We would like to make two points in relation to this paragraph.
Firstly, although residents of Southend Central Area have a low rate of car ownership, tourists visiting Southend Central Area, particularly the seafront, do not. The survey of visitors to Adventure Island undertaken by The Stockvale Group demonstrated that 85% of visitors to Adventure Island use the car. This is due to the high level of car occupancy for the largely family visitors (the same survey showed that 60% of family visitors had three or more passengers in their cars). It is difficult and expensive for this type of family user to access public transport. Of course, with such a high proportion of seats being used it is actually a sustainable method of travel in our view, with only 3% being single occupancy vehicles. It is therefore essential that policies in this Plan reflect this reliance on the private car, and the fact that for this type of visitor the use of a private car is not necessarily unsustainable. This is confirmed in the RPS Technical Note.
Secondly, if the improvements mentioned in this paragraph are put in place it is essential that care is taken that the supply of car parking spaces is not reduced in the Southend Central Area to such an extent that it causes displacement into car parks serving the seafront. The impact of changes to parking across the entire Central Area needs to be considered strategically. On the seafront itself there should be no loss of car parking spaces and, indeed, we strongly suggest that the SCAAP needs to positively plan for an increase in spaces to support the growth of businesses on the seafront, as set out in the Vision and Strategic Objectives (page 12).

Support

Representation ID: 2843

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

We support the improvement of signage and way-finding within and around Southend Central Area. This needs to include signage for drivers seeking car parking spaces from the main routes into Southend that are used by tourists who may not know which car parks are most appropriate for their purposes. It also needs to include improved way-finding within the Central Area, particularly those routes that link the main car parks to the seafront area as these routes are most likely to be used by visitors who do not already know the routes around the town.

Object

Representation ID: 2844

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? Yes

Sound? No

The Stockvale Group strongly objects to the use of the Car Parking Study that was commissioned by
Southend Borough Council and undertaken by Steer Davies Gleave as part of the evidence base of the SCAAP. There are numerous issues with this study, both in terms of its scope, methodology, surveys carried out and the extent to which it takes into account the specific needs of the seafront
tourism businesses.
Stockvale has commissioned transport planning consultants at RPS to review this from a technical perspective and the RPS Technical Note is attached to these representations (see below) and should be read alongside them.
The key conclusions are set out in our representations to Policy DS5.

Object

Representation ID: 2845

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? Yes

Sound? No

Please see our comments on Paragraph 130, as they apply equally to this paragraph and summarise our concerns about the significant flaws in the Study.
In relation to the points made in this paragraph, we make the following comments:
Paragraph 131 states that the Study "reviews current and future car parking provision in Southend Central Area". In our view, the Study does not correctly identify all capacity in the Central Area.
It states that the Study "sets out the performance of the existing parking network". The Study has not recorded correctly the performance of the car parks that serve the seafront area on peak days when the weather is good. These are the days (which can be relatively few) when the tourism
businesses need to be able to capture every visitor. These days essentially subsidise the operation of the attractions and other supporting businesses throughout the year. If visitors are lost due to lack of car parking then these businesses are less able to remain open at quieter times of year when tourism businesses traditionally lose money. This can also mean an inability to keep on staff, which makes the business (and ultimately Southend seafront) more of a seasonal operation. This will have a damaging effect on the economy of the town and its overall prosperity, when a sizeable proportion of the town's economy is supported by its tourism role. This model applies to pretty much all mainly outdoor tourism businesses. The author of these representations (Nick Laister of RPS) is a specialist planning consultant who has worked on projects in most of the UK's main seaside towns, including Blackpool, Southport, Rhyl, Weston-super-Mare, Exmouth, Southsea, Hayling Island, Isle of Wight, Eastbourne, Hastings, Margate, Lowestoft, Great Yarmouth, Skegness and Scarborough. These issues have emerged at a number of those resorts. It is an issue that is almost unique to the outdoor tourism industry but without an understanding of the need to accommodate the main peaks there can be significant harmful outcomes from ill-conceived policies.
Until the Study is amended to reflect these critical periods for the operators of seafront attractions it is not a suitable basis on which to build the policies that will impact upon the way the seafront operates.
This paragraph also mentions "the potential impact of development proposals on the network". We
do not consider that this has been adequately assessed, for the reasons set out in the RPS Technical Note.
This paragraph goes on to state: "It also assesses the economic importance of parking in Southend Central Area based on a recent survey of shoppers. As a result it provides a good indication of modes of travel and associated spend within Southend Central Area. It reveals that all visitors, including those who travelled by car, bus, train, cycle or walk, contribute to the local economy by spending in Southend Central Area." It is not clear why a similar survey was not undertaken of tourists visiting the town as these are equally important to the town's economy and have very different requirements (and, of course, their use focuses on different parts of the Central Area). The statement: "As a result it provides a good indication of modes of travel and associated spend within Southend Central Area" simply
cannot be justified as this only gives part of the picture. It does not give a picture of the needs of the seafront businesses, nor does it try to understand how visitors to Southend might have different requirements, patterns of movement, mode of travel, time of travel and priorities compared to
shoppers. This is a key reason why this section of the SCAAP is likely to be so damaging to the important seafront businesses..
As stated in relation to our representations on other policies and paragraphs, Stockvale carried out its own survey of visitors to Adventure Island, which more accurately reflects the requirements of visitors to the seafront area. This is summarised in the RPS Technical Note, which is submitted with these representations. It shows that there is a much greater reliance on car travel, a very high occupancy of vehicles and a high sensitivity to the availability of spaces and the difficulty in finding those spaces.
This Paragraph needs to be amended to reflect the needs of tourists visiting Southend

Object

Representation ID: 2846

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? Yes

Sound? No

Paragraph 132 again uses the Parking Study as its basis and this causes a number of errors or inappropriate conclusions. For example, it states that "The Study found that the Southend Central Area parking network rarely exceeds 85% occupancy." This masks the problems faced in the seafront
areas where there is currently a significant under capacity of parking spaces. Although this paragraph does acknowledge an imbalance, the Study fails to capture the extent of the issue as the survey dates used were not appropriate for understanding how tourism businesses operate and how
their visitors get to them (for example, inappropriate dates, surveys undertaken in poor weather).
This is covered in more detail in the RPS Technical Note. But looking at the dates used compared to the peak days recorded at The Stockvale Group's Adventure Island theme park and Sea Life Adventure attractions, it can be seen that the dates selected were far from representative of a peak day in the school holidays. The level of visitors to Southend seafront is primarily a result of the weather, and the consultants did not select appropriate days to understand the existing level of
pressure on car parks that serve the seafront, and therefore how sensitive the seafront businesses will be to change in this capacity.
As can be seen in our separate comments on policies that are partly based on this study, this has had
the effect of generating policies that do not support the seafront tourism businesses. Indeed, these
policies will have the effect of reducing visitor numbers and therefore investment into Southend
seafront.

Object

Representation ID: 2847

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? Yes

Sound? No

Paragraph 133 appears to acknowledge that more work needs to be done. Unfortunately, if the SCAAP is adopted before this work is done, and these policies brought into use, it will be difficult to avoid some very serious, long-lasting and damaging consequences for the businesses operating on the seafront.
Paragraph 29 of the NPPF acknowledges that different policies for sustainable travel are appropriate
for different areas:
"Transport policies have an important role to play in facilitating sustainable development but also in contributing to wider sustainability and health objectives...The transport system needs to be balanced in favour of sustainable transport modes, giving people a real choice about how they travel. However, the Government recognises that different policies and measures will be required in different communities and opportunities to maximise sustainable transport solutions will vary from
urban to rural areas."
In the case of Southend, visitors to the seafront attractions have different needs to residents using town centre facilities and a greater reliance on the private car (see our representations on paragraph 128). It is essential that the SCAAP differentiates in this way and takes these needs into account. This paragraph states that additional parking expected to be provided by development in Southend Central Area "is likely to accommodate future demand for parking generated in the plan period up to 2021". This, however, does not reflect the reality that there is likely to be a reduction in car parking spaces in the seafront area caused by the proposed SCAAP policies. This is caused by* the likely loss of car parking spaces (for example, Marine Plaza/Dizzyland, Seaways and
reduction of parking in the town centre);
* displacement of cars parked elsewhere in the Southend Central Area, where parking spaces will be reduced (noting that the Council's Car Parking Study underestimates the demand for
parking and incorrectly identifies capacity - see RPS Technical Note); and* demand created by the new developments proposed in the SCAAP/Core Strategy.
The SCAAP should be proposing increasing the spaces to allow for business growth, not reducing the number of spaces.
As stated above, the paragraph does acknowledge shortcomings and states that further work will be needed. The enclosed RPS Technical Note, which reviewed the Council's Parking Study, shows the extent to which this document is flawed as a basis for a planning policy document. The effects of implementing the SCAAP in its current form, informed as it is by the results of a flawed Parking Study
that does not grasp the nature and importance of tourist-related visitors and businesses, will be to harm the businesses on the seafront. The 'further work' referred to in this paragraph must be undertaken before the SCAAP is adopted. The Stockvale Group, and many of the other businesses on the seafront, would be happy to work with the Council, and share its existing survey data, to establish a more robust evidence base on which to build the policies of this Plan.

Object

Representation ID: 2848

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? Yes

Sound? No

Paragraph states that "collectively the car parks located in Southend Central Area have the potential to serve both the Town Centre and Central Seafront, facilitating linked trips and increasing
the potential for associated shared spend". This is not correct. As appears to be acknowledged in the second part of this paragraph, the town centre car parks are not all well located to accommodate visitors to Southend who are visiting for the seafront area. These visitors would not find it attractive
to park in car parks in the town centre, particularly those north of the railway line. There will undoubtedly be an opportunity for linked trips, but the most important factor for those operating businesses is to ensure that the visitors are able to get to Southend and park conveniently for the seafront. Once these people are parked, then they will be able to use both the seafront and town centre, especially if routes between the two are improved.
We know that convenience of car parking spaces is a major factor in the attractiveness of Southend as a tourist destination. The survey of Adventure Island visitors undertaken by The Stockvale Group (set out in the accompanying RPS Technical Note) shows that this is a very important issue for visitors.
When asked how important parking and the journey to Southend is in making a decision to come back again (on a scale of 1 to 10, where 10 is the highest importance), 10 was the category most
commonly provided by the 1,484 respondents, with 33% of respondents giving 10, and 65.03%
scoring this issue 8, 9 or 10. This cannot be underestimated. As stated in our representations to paragraph 58, return visits forms the basis of businesses such as Adventure Island, and they operate
in a very competitive environment. If visitors cannot get access to convenient car parks they may choose not to return to Southend. The tourism economy of the town relies on these day visitors, and a reduction in availability or attractiveness of parking will potentially reduce visitor numbers, shorten season, reduce employment levels and ultimately will reduce the attractiveness of Southend seafront. It is essential that the Plan recognises why tourism-related traffic has to be considered differently to traffic associated with journeys to work, school and other regularly used destinations.

Object

Representation ID: 2849

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? Yes

Sound? No

This paragraph states that there are 2,550 publicly available spaces to the south of the central area. As stated in the RPS Technical Note, this is actually closer to 4,000.It goes on to state that there will be "no net loss of public car parking to the south of the Central
Area."
Firstly, The Stockvale Group objects to this statement because it is a negative approach, not a positive one to meet the needs of businesses. The Stockvale Group have been planning for growth in
visitor numbers, supported by significant investments in their attractions Adventure Island and Sea
Life Adventure, as well as their numerous restaurants, cafes and kiosks on the seafront. It states in paragraph 28 that the Council's vision is to promote economic growth. Specifically, in Paragraph 29 it states that a Strategic Objective is to attract "greater visitor numbers", which is a direct reference to
the town as a resort. Paragraph 30 also reiterates that the Council is aiming to support growth. Similarly, in Paragraph 81, the Council states: "The tourism and hotel sector is expected to grow in
Southend over the next 20 years".
A policy of no net loss of public car parking spaces south of the Central Area will not support growth.
As Stockvale's surveys have shown (see the RPS Technical Note), the seafront tourism sector is reliant on visitors from outside the town who largely travel by car, with high car occupancies
(families). This Paragraph should be making a clear statement that the intention of the Council is to
increase the number of car parking spaces that provide convenient access to the seafront area. If this statement is not included, then this plan cannot be considered to be positively prepared as it is not meeting the needs of the seafront area. Equally seriously, it is not clear whether this approach will even be effective in protecting against net
loss of spaces as the Plan is not clear enough about how this is calculated. In order to make investment decisions. The Stockvale Group and other seafront traders need the certainty that
visitors will be able to access their attractions and other facilities that support tourists visiting Southend. A number of points need to be clarified:
1. It is not clear to Stockvale how the net loss will be calculated. As can be seen from the RPS Technical Note, the Council does not appear to have included all available spaces in and around Southend seafront in the capacity, nor accounted for all the demand. Given that, at peak times the seafront car parks are full, this is likely to result in an over-estimation of the
percentage of available spaces in Southend north of the railway line.
2. It is not clear whether the Council has taken into account the trips generated by substantial new development proposed, for example, at the Seaways car park site. If this has not been
taken into account, then there will be an immediate net loss on spaces due to displacement caused by traffic parking for the new developments. The RPS Technical Note suggests that this has not been correctly factored in.
3. It is not clear what level of importance will be attached to the most accessible spaces, or whether spaces nearer the town centre (some of which are up a steep slope from the main seafront area) will be considered as part of this 'net' figure.
4. Similarly it is not clear if the Council has considered spaces that have poor links to the seafront as part of this 'net' figure.

We support the Council's attempt to secure additional car parking spaces as part of the new Southend Museum development (approximately 220 spaces). However, this development is in thevery early stages, is not yet funded and cannot be relied upon. For the purposes of this policy, and in the timescales available to this plan, we do not consider much regard should be taken to this in assessing the availability of car parking spaces now and in the future.
In short we do not have the confidence that this policy is going to be effective. Indeed, it is likely on the basis of the work undertaken by RPS that this policy will be ineffective and actually counterproductive by resulting in a net loss of spaces available to visiting tourists. We are not confident that the Council is planning positively to accommodate growth, nor that its policies will be effective in ensuring no net loss.

Object

Representation ID: 2850

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? Yes

Sound? No

The first bullet point covers the same ground as paragraph 135. Please see our representations to paragraph 135. However, we wish to make the following additional points:
The first bullet point also includes the statements: "maintain overall capacity at a level that supports the vitality and viability of the SCAAP area, and enables the delivery of relevant Opportunity Sites". It is not clear whether this means that the levels of car parking will be increased to accommodate development at opportunity sites. If not, this could have a serious effect on the viability of seafront businesses that serve tourists travelling from outside the town. It is also important to note that the seafront area includes opportunity sites and therefore it is essential that any developments do not result in the loss of easily accessible spaces, as well as provide for their own parking needs.

Object

Representation ID: 2851

Received: 15/12/2016

Respondent: Stockvale Group

Agent: Stockvale Group

Legally compliant? Yes

Sound? No

We are very concerned about this Policy. It is partly based on the Car Parking Study (CPS), undertaken by Steer Davis Gleave, Reference 22958604, dated November 2016. The Stockvale Group commissioned a review of the CPS by RPS Transport. This review is summarised in the RPS
Technical Note submitted with these representations.
This review highlights a significant number of errors and omissions within the report which in our view demonstrate that this is not a robust evidence base on which to build policies on transport and access. In summary, these points include:
* No recognition of the fact that the Local Transport Plan 3 (LTP3) forecasts a 25% increase in parking demand by 2021, which is ignored throughout the document. LTP3 also recognises a
shortfall in seafront car parking in the summer.
* The report underestimates both parking supply and demand.
* The report severely underestimates tourism demand in the seafront area due to a number of omissions/errors. The RPS Transport Technical Note states that it has "no confidence" in the results for this area (Paragraph 66/67).
* The methodology used actually has the effect of suppressing peak demand and spreading it throughout the day (Paragraph 71) and makes no attempt to assess the true demand (Paragraph 75).
* Visitors to the seafront area choose not to use capacity elsewhere in the Central Area when it is available, but this is not recognised in the CPS (Paragraph 91).
* The busiest days for the seafront are not assessed (Paragraph 98).
* Key car parks are excluded from the calculations of the impacts of the Opportunity Sites. This seriously underestimates the number of spaces lost to development and overestimates parking availability.
* RPS concludes that the Opportunity Sites will result in a net loss of parking spaces, so will not cater for their own impact, let alone provide an increase in spaces to allow for the growth of Southend's seafront attractions. Indeed, the Opportunity Sites result in a loss of
car parking space in the areas where there is already significant pressure and a predicted significant increase by 2021.
* In addition, the visitor surveys were mainly undertaken in the Town Centre area, yet the report identifies the main car parking pressure as being the seafront, and there is little attempt to disaggregate the results.
* The recommendations mainly assist the Town Centre area, not the seafront.
We cannot rely on the CPS and we therefore do not consider policies that are clearly based upon the conclusions and recommendations of the CPS as being sound.
Our representations to Paragraphs 123 to 136 summarise a large amount of our concerns and should be read in conjunction with our representations on this policy.